III-V Compounds under the Microscope of European EHS Rules — What’s the Impact on the Industry?

III-V Compounds under the Microscope of European EHS Rules — What’s the Impact on the Industry?

The semiconductor
industry is a complex business with multiple challenges on many fronts,
including public policy. EU rules and regulations can be difficult to
understand and implement, and sometimes they place an additional burden that
slows down our fast-moving industry. To
help keep our industry competitive on a
global scale, SEMI Europe is committed to public policy — maintaining a
Brussels office, which advocates for the SEMI members early in the
decision-making process, so that final decisions reflect a balanced approach
that keeps the needs of our industry protected.

Ourania (Rania) Georgoutsakou is our new director of Public
Policy in Brussels. Rania has
over ten years’ experience in public policy and lobbying in Europe. She is
responsible for advocating for the interests of SEMI members with both the EU
and national governments. She evaluates and analyzes EU regulations which
affect the semiconductor, photovoltaic and related industries. In addition, she
manages the policy-related SEMI executive events (Brussels Forum, Executive
Summit) and is involved with the European Advisory Board.

By Rania Georgoutsakou, director, Public Policy, SEMI Europe

The potential impact of the EU’s environmental, health and safety (EHS) regulations on the semiconductor industry becomes reality, as the first III-V compounds begin a journey toward classification as hazardous substances. The semiconductor industry needs to demonstrate three things: III-V substances are essential and currently irreplaceable, the semiconductor industry is aware of the risks inherent to using these substances, and these risks are managed — based on strict standards that are reviewed and improved regularly

III-V Compounds in the
European EHS Process

European
EHS rules are probably most known for their complexity. Many regulations exist,
and a variety of substances are under always under review (with an array of
obligations forced on manufacturers). Keeping
up with all of this is literally a full-time job for many. So here’s a quick
look at where things stand for III-V compounds in Europe.

Two
III-V compounds, Gallium Arsenide (GaAs) and Indium Phosphide (InP), are
currently being evaluated under the European rules on classification, labeling
and packaging (CLP). They are being classified as carcinogenic, mutagenic or reproduction
toxic (CMR). This classification makes them eligible candidates for the list of
Substances of Very High Concern (SVHC), which in turn implies they may be subjected
to a restriction or authorization procedure, and possibly even a complete ban,
under REACH (European Regulation on Registration, Evaluation, Authorization and
restriction of CHemicals).

To
make a long story short: these compounds have started going through a process
that can lead to their restricted use and a possible total ban in the
medium-term.

The Basis of Key
Enabling Technologies — III-V Compounds

Key
Enabling Technologies (KETs) are now one of six priority action areas for
Europe’s industrial policy and they also have a prominent position in Europe’s
research and innovation strategy. So
Europe has clearly acknowledged the value of our technologies and is developing
policies to promote further innovation and growth in the sector.

The
semiconductor industry knows that III-V compounds are key ingredients for the
semiconductor manufacturing process that allow for smaller, faster and more
efficient products and applications. We now need to transmit this message to
the people in national ministries and EU institutions and start educating them
on the measures our industry has already implemented, and continues to improve,
to ensure the safety of workers, consumers and the environment.

These
are still the early days, as the compounds in question are still at the
classification stage and their future route through the EHS process remains
uncertain and depends on a number of things. But now is the time to start
explaining how these compounds are used in the semiconductor industry, why they
are important, and what risk management measures the industry has already
taken.

Dr. Nelly Kernevez, Partnership Director for SOITEC, has joined SEMI in raising awareness among European and national decision-makers about the use of III.V compounds in the semiconductor industry. She addressed a group of representatives of national ministries for industrial policy, including the REACH sub-group of the Enterprise Policy Group, in Brussels on 30 November 2012 and explained the strategic importance of III.V compounds and the end-products they are found in. SEMI members are concerned that restricting the use of these compounds under EU EHS rules will have an adverse effect — not only on the European semiconductor industry — but on Europe’s overall growth strategy.

Europe Competitiveness:
Importance of III-V Compounds

On
the one hand, III-V compounds are the key ingredients for Europe’s KETs, i.e.,
the technologies that will allow Europe to tackle societal challenges such as
climate change, energy efficiency and an ageing population and that will also contribute
to economic growth and competitiveness. III-V compounds have specific
properties that are not replaceable today — eliminating them would mean
sacrificing speed, efficiency and innovation potential.

On
the other hand, the semiconductor industry is very much aware of the risks
associated with certain substances. This is why for years we have been
developing EHS standards in associations such as SEMI, where companies put
aside any concerns about working with competitors and jointly develop risk
management standards and benchmark with each other. Consumers are not exposed
to these substances, as they are encapsulated, inert and bulk. We work together
to implement European and other regulations on waste and safely dispose of any
harmful elements. The risks are known and managed responsibly.

This
does not need to become a choice between promoting growth on the one hand, and
providing a high level of safety on the other. We can demonstrate that the semiconductor
industry is already managing the risks — and that there is no need to restrict
or ban the use of these compounds.

SEMI will continue to
monitor developments in this area and work with members to raise awareness
about the use of these compounds and the risk management standards in place. For
further information, please contact Ms. Ourania Georgoutsakou, director, Public
Policy Europe, at gourania@semi.org.

In
addition to Advocacy, SEMI is involved in strategic positioning, roadmaps and
positioning papers, issue forums, exhibitions, and executive events. For more
information on SEMI Europe, please visit www.semi.org/eu.